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@M-MTax 

You're making unproven assumptions as well.  What would really be needed (I suppose) is to determine the actual percentage of ownership that was gifted each year.  Something like this (which also takes into account the improvements, which are added to the basis when made).

 

 

 

Year FMV Amount of gift Percentage of FMV transferred Basis Amount of basis transferred
2010 $185,000 $26,000 14.0% $185,000 14.0%
2011 ?? $26,000 ?? ?? ??

 

and so on.